New US Subpart F Tax Regulations Address Foreign Partnerships, Active Rents, and Royalties Exception

Steptoe's Amanda Varma and Brigid Kelly authored an article in MNE Tax titled "New US Subpart F Tax Regulations Address Foreign Partnerships, Active Rents, and Royalties Exception."  The article, published November 10, discusses the final regulations issued by Treasury and the IRS addressing various issues arising under subpart f, which is designed to prevent the deferral of passive or mobile income through the use of controlled foreign corporations.